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Transfer pricing
Dear All,
I have one querry related to international transfer pricing issue based on practicle experience.
Facts : There is a domestic company a subsidiary of a foreign commpany. TO avoid litigation and money and energy it has routed all its transaction through another non related company under a mutual agreement. Under the agreement that non-related party purchases materials from that foreign company and sells it to its indian subsidiary company. Now there exitsts an associated enterprieses but no trasaction during the year was shown but materials were purchased from it through another indian comapny.
Querry : (1) Shall those transaction which were routed will be covered for transfer pricing ? Considering that we know this arrangement but the department will never come to know.
(2) Shall that non-related indian company through which transactions were routed will also be covered under the definition of associated enterprieses.?
Please discuss.
Thank You
Replies (1)
Dear Mitesh Sir,
The transaction will be covered for TP Regulations under Section 92B(2).Its true that its tough for Department to capture such transactions but its not impossible. I even wanna know that whether such transaction will get covered under S.92A(2)(m)?
But even I want to know that who will now be the AE of Indian subsidiary- the Foreign Parent or the Indian Entity?
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